Distilled Spirits Specialty Products: Label Must be Consistent with TTB-Approved Formula
Want to get your label approved faster? Prior to submitting your next Certificate of Label Approval (COLA) application for a distilled spirits specialty (DSS) product, please ensure you have an approved formula that includes all of the ingredients claimed on your label.
Recently we have seen an uptick in the number of COLA applications for DSS products with a proposed label that does not align with the associated TTB-approved formula. We are not able to approve any COLA application that is not consistent with the associated TTB-approved formula.
Below are examples of the kinds of errors we are seeing:
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What the label reads:
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Issue:
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Suggested Change that would meet the requirement:
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Statement of Composition Errors
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“Rum with Natural Strawberry and Lime Flavor”
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The approved formula does not disclose the use of natural strawberry flavor.
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Option 1: Obtain formula approval for rum made with natural strawberry and lime flavor.
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Option 2: Remove the reference to “natural strawberry” from the label.
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Class/Type Designations that Appear in the Additional Information
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“This whisky was made on a midsummer day.”
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This example is for a “Whisky with Natural Cucumber Flavor” as indicated in the class/type designation elsewhere on the label application and in the associated approved formula.
The full class/type designation, which includes “natural cucumber flavor” in this case, must also be stated in the additional information on the label.
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Option 1: “This whisky with natural cucumber flavor was made on a midsummer day.”
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Option 2: “This refreshing beverage was made on a midsummer day.”
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DSS Labeling Guidance
To avoid any delay in getting your DSS COLA application approved, please review the material on TTB’s distilled spirits labeling public guidance page.
Relevant Regulatory Citations
Additional Information 27 CFR 5.56
Class, Type, or Other Designation Requirement 27 CFR 5.63(a)(2)
Distilled Spirits Specialty Products 27 CFR 5.156
Statements of Composition 27 CFR 5.166
TTB Proposes 2 New American Viticultural Areas
 On March 29, 2023, we published two proposed rule documents in the Federal Register, each proposing to establish a new American viticultural area (AVA), or grape growing region. We are issuing these proposals in response to petitions submitted on behalf of local vineyard owners and vintners. We designate viticultural areas to allow vintners to better describe the origin of their wines and to allow consumers to better identify wines they may purchase.
The comment period for both proposed rules closes May 30, 2023.
Comptche: In Notice No. 222, we propose to establish the 1,421.8-acre Comptche viticultural area in Mendocino County, California. While it is located within the North Coast AVA, the petitioner requests to exclude the proposed AVA from the North Coast AVA due to significant differences in distinguishing features. See Docket No. TTB–2023–0003 at Regulations.gov for all documents related to this proposed rulemaking and to electronically submit a comment.
Contra Costa: In Notice No. 223, We propose to establish the approximately 167,146-acre Contra Costa viticultural area Contra Costa County, California. The western portion of the proposed AVA partially overlaps the established San Francisco Bay and Central Coast AVAs. To avoid this partial overlap and add regions that contain their respective distinguishing features, we also propose to expand the boundary of both established AVAs to entirely encompass the proposed Contra Costa AVA. The proposed expansions would add approximately 109,955 acres to each of the established AVAs. See Docket No. TTB–2023–0004 at Regulations.gov for all documents related to this proposed rulemaking and to electronically submit a comment.
Visit Us at WSWA 2023 Access Live!
 If you plan to attend the Wine & Spirits Wholesalers of America (WSWA) 2023 Access Live in Orlando, FL, come visit the TTB team April 3-4! TTB specialists will be available at Booth 231 throughout the conference to answer questions. So whether you want to learn more about permits, reporting, have questions about compliance, or would just like to say hello - come see our team!
U.S. Customs and Border Protection: Trade Facilitation and Cargo Security Summit 2023
 TTB-regulated tobacco industry members may find this notice of interest.
SOURCE: Federal Register / Vol. 88, No. 57 / Friday, March 24, 2023
AGENCY: U.S. Customs and Border Protection, Department of Homeland Security
ACTION: Notice of 2023 Trade Facilitation and Cargo Security Summit
SUMMARY: This document announces that U.S. Customs and Border Protection (CBP) will convene the 2023 Trade Facilitation and Cargo Security (TFCS) Summit in Boston, MA, on April 17–19, 2023. The 2023 TFCS Summit will be open for the public to attend in person or via webinar. The 2023 TFCS Summit will feature CBP personnel, members of the trade community, and members of other government agencies in panel discussions on CBP’s role in international trade initiatives and programs. Members of the international trade and transportation communities and other interested parties are encouraged to attend.
DATES: Monday, April 17, 2023 (opening remarks and general sessions, 8 a.m.–
5 p.m. EDT), and Tuesday, April 18 and Wednesday, April 19, 2023 (breakout sessions, 8 a.m.– 5 p.m. EDT).
TTB Career Opportunities: Chemist, Statistician, and Tax and Trade Formula Specialist
Are you interested in a career at an agency that ranks in the top 10% of Best Places to Work in the Federal Government? If yes, consider applying for this TTB job.
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